Policy Documentation

Modern Slavery Policy

Policy Brief

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 01 April 2024. Digital Transformation Advisory Limited is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance toward slavery and require our supply chain to comply with our values.

Organisational Structure and Supply Chains

Digital Transformation Advisory Limited has business operations in the United Kingdom, supplying our clients with advisory services from staff in the UK and partnering with select partners for remote technology staff in a resource augmentation or technology solution delivery model. We operate in the financial services and technology sectors.

Our suppliers in remote locations, India and Eastern Europe are risk assessed in relation to slavery or human trafficking, is reduced by ensuring they provide for each candidate:

• Ensuring all staff provided have residency rights for the country
• Conducting a check of education history
• Confirmation of recent employment history
• Background criminal checks with the relevant authorities in the country

Performance Indicators

We have reviewed our key performance indicators (KPIs) to align with this policy. As a result, we are:

• Requiring all staff/supply chain managers/HR professionals to have completed training on modern slavery within their probation period.
• Have developed a system for supply chain verification, whereby we evaluate potential suppliers before they enter the supply chain.

Responsibility

Responsibility for our anti-slavery initiatives is as follows:

• Policies: Legal and CEO develop and review policies and ensure they are followed.
• Risk assessments: Suppliers of third-party staff are the highest risk and both the suppliers and the staff they provide are assessed and evidenced during the selection and onboarding process.
• Training: HR and managers are provided with training material and reviewed during induction and again when assigned to supplier assessment and staff interviewing.

The Company requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. The Company's training covers:

• How to identify the signs of slavery and human trafficking.
• What initial steps should be taken if slavery or human trafficking is suspected.
• How to escalate potential slavery or human trafficking issues to the relevant parties within the Company.
• What external help is available.
• What steps the Company should take if suppliers in its supply chain do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company's supply chain.

Relevant Policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy: We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
• Employee code of conduct: Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• Supplier/Procurement code of conduct: We are committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
• Recruitment/Agency workers policy: We use only specified, reputable employment agencies to source labour and always verify the practices of any new agency it is using before accepting workers from that agency.

Privacy Statement

Privacy Notice

The Digital Transformation Advisory Privacy Notice concerns the nature, scope and purpose of collecting, processing and using the personal data which is connected with visiting our website, conducting correspondence, participating in events and other forms of contact.

Because we process your personal data you have the right to:

• Request access to personal data concerning you, including information on the processing of such data
• Rectify or complete personal data if it is incorrect or incomplete
• Request the erasure of personal data (right to be forgotten) if there is no longer any legal basis for processing or when your consent to process the data has been withdrawn
• Object at any time to the processing of your personal data based on our legitimate interests. After objection, we will not process your personal data for these purposes unless there are compelling legal basis for such processing which override your interests, rights and freedoms or there are grounds for establishing, pursuing or defending claims.
• In particular, you have the right to object at any time to the processing of your personal data for direct marketing purposes, in which case we will not process your personal data for such purposes
• Withdraw your consent to processing at any time. The withdrawal of consent does not affect the lawfulness of the processing of your data that was carried out on the basis of the consent given before its withdrawal
• Request the restriction of processing if it is inaccurate, unnecessary, processed without a legal basis or if an objection has been made to the processing on the basis of a legitimate interest of the Controller
• Receive and transfer personal data in a structured, commonly used format, to reuse your personal data for your own purposes across different services, in the case of data provided to the Controller and processed on the basis of your consent

Please contact dataprotection@digital-transformation-advisory.com